SFDR reporting with every annex drafted from fund data, every figure traced and every promise checked
Every annex drafted from fund data, every figure traced, every promise checked.
See one case, screen by screen ↓SFDR Reporting is software for SFDR reporting at asset managers: eight AI agents draft each Article 8 and 9 fund's periodic annex (Annex IV or V) and the entity PAI statement from the firm's own holdings and adverse-impact data, trace every figure to its source and check every result against the fund's promises before publication. The ESG product manager prepares, compliance checks, the Head of Sustainable Investing signs any missed minimum and the board approves.
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SFDR reporting comes back every year, for every fund. Every EU fund that promotes environmental or social characteristics (Article 8) or has a sustainable investment objective (Article 9) publishes a pre-contractual annex and, with its annual report, a periodic annex in the Annex IV or Annex V template of Delegated Regulation (EU) 2022/1288. Firms with more than 500 employees also publish an entity-level PAI statement each June 30. At a manager with 300 Article 8 and 9 funds, that is 600 annexes a year, and the periodic annexes of a single umbrella can need some 1,190 language versions in one cycle.
Most of it is still done by hand. Quarter-end holdings and adverse-impact data are pulled into spreadsheets, gaps are filled with vendor estimates and few teams track which figures are reported and which are estimated, narratives are typed, and translators re-key every number. The check that matters most — did each fund do what it promised? — is a sample, in English. A missed minimum found after publication is a misstatement in a regulated document, and the SFDR 2.0 proposal of November 20, 2025 would replace Article 8 and 9 with new product categories, each with a 70% minimum, so every fund has to be mapped again.
Estimated split for one umbrella's periodic annexes, from the data cut to board approval, by hand and with the solution.
Eight agents draft, trace and check every annex; product prepares, compliance checks, the board approves.
Quillfield Investment Funds SICAV, a Luxembourg UCITS umbrella with a June 30 year-end, must publish its annual report with 186 periodic annexes — 158 Article 8 and 28 Article 9 — by October 31, 2026. The board meets on Tuesday, October 27. It is Tuesday, October 20, 9:41 a.m. in London. Here is what happens next, screen by screen, in the working solution.
Clara's Today screen opens on four numbers: 186 periodic annexes due October 31, all drafted; 142 ready for the board; 4 promises missed or at risk out of 1,912 checked; 1,174 of 1,190 language versions drafted. The first item under “Needs you” reads: Euro Climate Leaders missed its 90% minimum. Beside it is what the agents did overnight, every line cited.
“Drafted 186 periodic annexes in the official templates: 39,804 figures, each with its lineage.” — Drafting agent, 2:44 a.m.
Quillfield Euro Climate Leaders — Article 9, €2.84 billion net assets, reference period July 1, 2025 to June 30, 2026 — opens in the official periodic template. Clara selects 87.0%. The margin walks it back in four steps: 252 position rows over four quarter-ends, reconciled to the fund administrator's NAV; the sustainability test under methodology v3.2, with 57 of 64 holdings qualifying at June 30; the average of the four quarter-end shares, 91.8%, 91.4%, 84.6% and 80.2%; and the value printed in the annex, compared with the promise.
“4 steps · sources verified” — and a second tag: “Below the promise”.
A red banner says the fund held 87.0% sustainable investments against the 90% minimum promised in its pre-contractual annex, on page 412 of the prospectus. Clara asks the Consistency agent to re-check, and its run is shown step by step: six binding promises across five documents — the pre-contractual annex, the prospectus, the fund-name rule, the website and factsheets in nine languages — read against the result; 5 met, 1 not met.
“Hand off: explanation drafted for people to decide — Clara Whitmore prepares → Tomás Ferreira checks → Dr. Hannah Okoye signs.”
The agent's draft names three holdings that stopped qualifying: Vellmar Energie AG failed “do no significant harm” after its non-renewable generation rose to 61%; Solenne Énergies SA failed good governance after a formal notice on labor practices; Kaito Rail Systems failed the contribution test when its sustainable revenue fell to 14%. Had they qualified, the average would have been 92.0%. Vellmar was sold on July 9 and Kaito on August 14, and the share has been above 90% since — 93.1% at September 30.
The Consistency agent never decides whether a breach is material, and never softens a result.
Clara opens the Vellmar citation. The Geschäftsbericht 2025, page 47, published March 19, 2026, sits beside the Intake agent's English reading, with 61% highlighted in both and the read at 99% confidence. Below it is where the figure is used: the sustainability test it fails under methodology v3.2 §4.2, and the annex's explanation of the missed minimum.
“Translation kept beside the original; the figure is the original's.”
Clara sends the annex to compliance; her own Approve button stays locked. Tomás Ferreira, in Luxembourg, opens it with the review clock running to Friday, October 23. He checks the lineage, chooses the reason code “Breach disclosed — remediation evidenced” and his note for the record reads: “Lineage of 87.0% checked to holdings and the three issuer reports; sales confirmed in the OMS.” The Head of Sustainable Investing signs the explanation next.
“The preparer of an annex can never approve it (maker-checker).”
The Checks screen holds the whole cycle: 1,912 promises in 186 funds, 1,904 met, 4 alerts, 4 on watch within two points. One alert is not in an annex at all. The German factsheet for Asia Pacific ESG Leaders says “über 30 % nachhaltige Investitionen”, while the annex shows 23.5% against a 20% minimum; the English, French and Italian factsheets say 23%. The agent has drafted the German correction for marketing.
Next step: “Marketing corrects the factsheet; compliance confirms.”
Euro Climate Leaders is distributed in eight languages beside English. In the German version, 214 of 214 figures match the English: the Translation agent used the template's own German headings and the firm's glossary v13, and copied the numbers rather than translating them. Lena has approved the German wording. The new explanation paragraph is held in every language.
“The English paragraph is new and not yet approved by compliance and the Head of Sustainable Investing. No translation of it can reach a market until it is.”
On the September 30, 2026 holdings and the Commission text of November 20, 2025, 224 of 300 funds fit a proposed category: 31 Sustainable, 22 Transition and 171 ESG basics. 76 fit none, and 63 of those have sustainability words in their names. Each fund shows its 70% test, its exclusions and why. Under the Parliament position, two funds move from Sustainable to Transition.
“These are proposals: no fund's classification changes until you approve a plan.”
The Board Pack agent has 142 annexes ready for the board on Tuesday, October 27. The pack opens with a one-page summary, then the four promise-versus-result alerts with their explanations and evidence, the annexes to approve, the watch list, a resolution draft and an evidence index of lineage, sources, approvals and reason codes. The draft resolution names the explanation of Euro Climate Leaders' missed minimum.
“I put the 4 exceptions first in the pack; only people approve, record and publish.” — Board Pack agent
The same reporting cycle, seen by five of the people who carry it — what the autumn looked like, and what it looks like now.
Eight agents draft, trace and check every annex; product prepares, compliance checks, the board approves.
Pulls quarter-end holdings and adverse-impact data from two ESG data vendors, reads issuer annual and integrated reports in their own language to fill gaps, and marks every value reported or estimated.
Computes the 18 PAI indicators from quarter-end averages, the sustainable-investment share, top investments, sectors and asset allocation.
Tests every holding at each quarter-end for contribution, no significant harm and good governance under the firm's methodology, and explains each pass or fail with its sources.
Fills Annexes II to V in the template order, writes the narrative from the period's facts and links every figure to its lineage.
Compares each result with every promise — the pre-contractual annex, prospectus, fund-name rule, website and factsheets in every language — and drafts the explanation of a missed promise with the holdings cited.
Maps every fund to the proposed SFDR 2.0 categories under the Commission and Parliament texts, with the 70% test, the minimum exclusions, names at risk and a gap plan.
Drafts each language version with the template's own headings and the firm's glossary, locks every figure to the English, and holds versions whose English changed.
Assembles the board pack with the exceptions first, the resolution draft and the evidence pack for audit.
Maker, checker, signature, approval. The agents propose; a named person decides.
Every screen has the agents in the conversation. Ask why a fund missed, what is ready, or what SFDR 2.0 changes — every answer cites its source, and some act for you, but sending, approving and publishing stay with people.
Why did Euro Climate Leaders miss its minimum?
Three holdings stopped qualifying during the period: Vellmar, Solenne and Kaito, each cited to the issuer's own report. Their weight at the quarter-ends they failed averages 4.95 points; had they qualified, the average would have been 92.0% against the 90% promised.
Which annexes can go to compliance today?
11 of the 14 annexes still with the product team can go to compliance today: every figure traced, no open exception, all promises met. The other 3 wait for data exceptions due by the Thursday data lock. I have selected the 11 for you; sending stays your decision.
What changes under the Parliament position?
Under the Parliament position the green-aligned route for Sustainable products rises from 15% to 20%. Two funds move from Sustainable to Transition, each 17% green-aligned, so Sustainable goes from 31 to 29 and Transition from 22 to 24. ESG basics (171) and the 76 with no category do not change.
What happens if vendor B does not deliver?
Vendor B sends controversy and UN Global Compact flags. If today's file does not arrive, I keep the October 13 delivery for this run and mark every governance test that used it, so a reviewer sees which flags are a week old. The data lock on Thursday, October 22 does not move.
13 screens from the working solution, on its sample data. Pick one to see it large.
How every annex is tested, checked and escalated — all settings, and a change takes effect only when a second person approves it.
| Setting | Default | Choose from |
|---|---|---|
| Sustainable investment methodology | v3.2, in force from Feb 1, 2026 | Approved by Dr. Hannah Okoye; v3.1 and v3.0 kept on record |
| Contribution: sustainable revenue at least | 20% | Raised to 20% in v3.1 |
| Watch band above any minimum | 2.0 points | Funds inside it go on the watch list and a weekly digest |
| Explain a year-on-year change over | 10% | Each change gets its sentence in the annex |
| Issuer value read below this confidence | 95% | Goes to a person before it is used |
| Fund-name rule (ESMA guidelines) | 80% | Checked at every quarter-end |
| SFDR 2.0 category test | 70% | Commission text or Parliament position |
| Compliance review clock | 3 business days | At 4 business days the Head of Compliance is told by email |
Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.
“demo” = seen in the working solution, on its sample fund data · “target” = the design goal, measured in the live solution · “estimated” = our estimate · “typical” = published figures (Frankfurt Public Prosecutor's Office €25 million greenwashing fine, April 2025, and SEC $19 million ESG settlement, 2023). Regulatory context: Delegated Regulation (EU) 2022/1288; European Commission SFDR 2.0 proposal, November 20, 2025, and the European Parliament's position; ESMA guidelines on fund names. People, firms, funds and issuers named on this page are fictional — characters and sample data in the working solution.
SFDR Reporting is software for SFDR reporting at asset managers: eight AI agents draft each Article 8 and 9 fund's periodic annex (Annex IV or V) and the entity PAI statement from the firm's own holdings and adverse-impact data, trace every figure to its source and check every result against the fund's promises before publication. The ESG product manager prepares, compliance checks, the Head of Sustainable Investing signs any missed minimum and the board approves.
Each Article 8 or Article 9 fund publishes a pre-contractual annex (Annex II or III of Delegated Regulation (EU) 2022/1288) and a periodic annex attached to its annual report — the SFDR Annex IV template for Article 8, the Annex V template for Article 9 — in use since January 1, 2023. Managers with more than 500 employees also publish an entity-level statement of principal adverse impacts each June 30. The solution drafts the periodic annexes in the template order and the PAI statement with its 18 mandatory indicators, each with its lineage.
A PAI statement, or principal adverse impact statement, is the manager's entity-level report of how its investments affect sustainability factors, such as greenhouse-gas emissions, fossil-fuel exposure, UN Global Compact violations and board gender diversity, set against the previous year. In the solution, every value in the statement opens to its lineage: the holdings, the adverse-impact data and its coverage, the formula, and the value printed.
The Consistency agent compares every periodic result with every binding element in the pre-contractual annex, the prospectus, the fund-name rule, the website disclosure and the factsheets in every distribution language. This promise-versus-result check is the solution's greenwashing control. When a promise is missed it drafts the explanation with the holdings cited and hands it to compliance. In the working solution it checked 1,912 promises and found 4 alerts, including a German factsheet that claimed more than the annex showed.
The Commission's SFDR 2.0 proposal of November 20, 2025 would replace today's Article 8 and 9 disclosures with three product categories — Sustainable, Transition and ESG basics — each needing at least 70% of assets aligned with its objective, plus minimum exclusions. The proposal is still in negotiation and would apply 18 to 24 months after it enters into force. The SFDR 2.0 Mapping agent runs that test on every fund under the Commission text and the Parliament position, explains any gap and flags fund names at risk. Nothing changes until the Head of Sustainable Investing approves a plan.
The periodic annex is published with the fund's annual report — for a UCITS, within four months of its year-end, and for an AIF, within six — and the entity PAI statement each June 30 for the prior calendar year. In the working solution the umbrella's year-end is June 30, so 186 annexes are due with the annual report on October 31, and the board meets on October 27.
People decide. The agents never change a promise, a fund's classification or a number in a translation, never decide whether a breach is material, and never publish or record a board decision. The preparer can never approve the annex, compliance approves with a reason code, and every action is on a hash-chained audit trail.
The Agentic Solution Engine builds and deploys it from your requirements and documents — your sustainable investment methodology, pre-contractual annexes, prospectuses and a past cycle's annexes — and it goes live once every quality gate has passed. We will walk you through it on your own funds first.
Issuer questions answered in minutes, every claim pinned to its source page.
1-min demoESG Data ExtractionHoldings move from estimated to reported ESG data, each figure cited to its page.
1-min demoPortfolio Company ESG Data CollectionEach company confirms prefilled values, and no outlier reaches an LP unexplained.
1-min demoWe'll run SFDR Reporting on a sample of your own funds, their promises and last cycle's annexes.